This Privacy Policy outlines the principles under which DIGITAL HEALTH PTE LTD and our medical partners ("Health Screening Centre Pte Ltd", “Kingsway Medical Clinics”, "we", "us", or "our") may gather, utilize, disclose, or otherwise handle your personal information when using our website at http://www.digitalhealth.sg ("Website") and/or the Digital Health: Eden mobile apps ("Software/Application(s)"), in compliance with the Personal Data Protection Act 2012 ("PDPA").
This Privacy Policy is applicable to personal information in our possession or under our control, including personal information held by organizations we have engaged to gather, utilize, disclose, or process personal information for our objectives. If you disagree with this Privacy Policy and our Terms and Conditions, please refrain from using any of the Platforms. Your ongoing use of the Platforms and our services signifies your acknowledgment and acceptance of this Privacy Policy.
As our partnering medical provider, Kingsway Medical Clinics Group (collective for all Kingsway Medical Clinics) may gather, utilize, handle, and disclose personal information that has been shared with or gathered by them under this Privacy Policy, as it is updated periodically, for the purposes of providing medical care. Your continued use of the video consultation feature following any changes indicates acceptance of any revised privacy policy.
Digital Health is not responsible for any gathering, usage, handling, or disclosure of your personal information by Kingsway Medical Clinics. For additional information, please refer to the section "Disclosure to Kingsway Medical Clinics" below.
Other definitions in this privacy policy:
"Customer" refers to an individual who has engaged with any of our platforms in any way or has entered into a contract for the provision of healthcare services or products.
"Kingsway Medical Clinics" refers collectively to: (a) Kingsway Medical (Bukit Timah) Pte. Ltd.; (b) Kingsway Medical (Braddell) Pte. Ltd; (c) Kingsway Medical (Seng Kang) Pte. Ltd. (d) Kingsway Medical Pte. Ltd.
"Personal data" refers to any data about an individual who can be identified from that data, either on its own or in combination with other information that is in the possession of, or likely to come into the possession of, a data user.
Other terms utilized in this Privacy Policy shall have the meanings assigned to them in the PDPA (where the context permits).
2. PERSONAL INFORMATION PROVIDED BY THE INDIVIDUAL
Depending on the user’s interactions with us and the Services, we may collect various types of personal and sensitive information from you. The personal information we gather is based on your choices and the features you use, which may include:
(a) Full name, Identification numbers (such as NRIC, Passport Number, FIN)
(b) Residential address, email address, phone number, nationality, gender, date of birth, contact preferences, billing addresses, debit/credit card numbers, and contact or authentication data;(b) Health-related data you provide, such as medical history, health condition, laboratory test results, diagnostic images, photographs, reports and medical claims;
(c) Medical and health information prepared by healthcare professionals or treatment providers who deliver services and products to you through the Platforms, including medical records, treatment and examination notes, laboratory test outcomes, and diagnostic images;
(d) Billing details, including credit card or online payment system account information;
(e) Information about the computer or mobile device you use;
(f) Geographical location or address;(g) Biometric data or information revealing race or ethnic origin, when necessary and permitted by applicable law or with your consent;(h) Any other information you input into the Platforms or associated services.
Please ensure that all personal information you provide to us is accurate, complete, and up-to-date, and inform us of any changes to such information. The individual is responsible for submitting truthful and accurate information, and our company will not be responsible for errors or omissions made by the individual.
3. GATHERING, UTILIZATION, AND DISCLOSURE OF PERSONAL INFORMATION
3.1 We generally do not collect your personal information unless (a) the individual or an authorized third party provides it to us voluntarily for the purposes outlined in this Privacy Policy, including your employer or insurer if they process your medical care claims. (b) We may collect and use your personal information without your consent if it is permitted or required by the PDPA or other laws.
3.2 Age Requirements Our application is for users who are 18 years or older. We do not collect information from or market to individuals under 18 years of age. If we discover that we have collected personal information from users under 18 years of age, we will deactivate the account and delete such data from our records. If you find any data we may have gathered from children under 18, please contact us at [email protected].
3.3 We may gather and utilize your personal data for one or more of the following objectives:
(a) To enable you to create and access your account, and to ensure that your account functions properly. This includes facilitating account creation, authentication, and account management.
(b) To deliver or facilitate delivery of services requested by you (including any medical or healthcare services and the shipment of products purchased by you);
(c) To verify your identity;
(d) To provide support to our users, addressing, managing, and processing inquiries, requests, applications, complaints, and feedback from you;
(e) To facilitate payment or credit transactions for the provision of goods and services;
(f) To improve the quality of medical or healthcare services by performing quality assessments and similar activities;
(g) To generating de-identified data, which is information not used or intended for personally identifying an individual (e.g., aggregate statistics related to the utilization of the services on the Platforms);
(h) To inform you of updates to our platform;
(i) For advertising and promoting the Platforms, as well as the services and products offered on the Platforms to you;
(j) To providing you with health and wellness information;
(k) To comply to any relevant laws, regulations, codes of practice, guidelines, or rules, or supporting law enforcement and investigations conducted by any governmental and/or regulatory authority; We may collect, use, and disclose your personal data without your consent to detect and prevent fraudulent activities and misuse of our services (c.f. "legitimate interests" exception under PDPA).
(l) To transform personal data into anonymized data for the purposes of analytics and research in order to improve health outcomes;
(m) For any other objectives for which you have supplied the information;(o) To communicate with unaffiliated third parties, including our third-party service providers and agents, and pertinent governmental and/or regulatory authorities, both in Singapore and overseas, for the aforementioned objectives
3.4 Consent to being contacted by the company & partnering entitiesIn the event we contact you for any of the above objectives, you consent to being contacted via email, text, or call at the email address or telephone number provided to us by you or your Authorised Representative.
3.5. Disclosure of Personal Data to Kingsway Medical Clinic(s)If you use our platform for health-related services provided by Kingsway Medical Clinic, any personal data collected or derived during a "Digital Health" video consultation with Kingsway Medical Clinic doctors will be disclosed to Kingsway Medical Clinic. This may include your medical records, documentation, or reports. Kingsway Medical Clinic(s) may gather, use, process, and disclose this personal data in accordance with our privacy policy.
3.6 Use of anonymous data
In addition, while using our platform(s), we may passively gather specific information that doesn't directly reveal your identity. This may include device and usage data, such as IP address, browser and device features, operating system, language preferences, referring URLs, device name, country, location, and details about your usage of our Services, as well as other technical data. The primary purpose of collecting this information is to maintain the security and operation of our Services and for internal analytics and reporting. Like many companies, we also gather data through cookies and similar technologies.The collected information may comprise:(a) Web Analytics, Log and Usage Data:We collect and record service-related, diagnostic, usage, and performance data automatically when you use our Services. This includes your IP address, device information, browser type, activity details, and device event data such as error reports or hardware settings. (b) Device Data: We collect device data, which includes details such as your IP address, device and application identification numbers, location, browser type, hardware model, and operating system, about the computer, phone, tablet, or other devices you use to access our Services.(c) Real-Time Location: Some features of the Platforms use GPS technology to gather real-time information about the location of your device, allowing the Platforms to connect you with a medical provider near you.
4. We may share your personal data when:
(i) such sharing is essential for fulfilling obligations during or in relation to our provision of goods and services you request; or
(ii) for any purposes mentioned above:
(a) With our subsidiaries, associated companies, affiliates, or partners;
(b) With relevant parties who may handle your claims for medical care (which may include your employer or insurer if you file claims under your employee or insurance benefits scheme or policy). In such cases, we might disclose your medical diagnosis/information to those parties for claims processing and/or utilization verification, if required by them;
(c) With contractors (including specialists and other healthcare providers), service providers, and other third parties we engage to support our business, who are contractually obligated to maintain personal information confidentiality and use it solely for the purposes we disclose it to them (including logistics service providers and data service providers);
(d) As mandated by law, which can encompass providing information as required by a court order;
(e) When we genuinely believe that sharing is necessary to protect your safety or the safety of others, safeguard our rights, investigate fraud, or respond to a government request;
(f) To a purchaser or other successor in case of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Digital Health or Kingsway Medical assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data maintained on the Platforms is among the assets transferred;
(g) To any other individual or organization revealed by us when you provide the information.
5. The purposes mentioned in the above clauses may persist even in situations where your relationship with us (for example, due to your employment contract should you be hired) has ended or changed in any manner, for a reasonable time thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
6. This Privacy Policy solely applies to information we gather through the Platforms and in email, text, and other electronic communications sent through or in connection with the Platforms. This policy does not apply to information collected by any third party. When you click on links on the Platform, you may exit our site. We are not accountable for the privacy practices of other sites, and we encourage you to read their privacy statements.
7. Your consent for the collection, use, and disclosure of your personal data will remain valid until you withdraw it in writing. You may revoke consent and request that we stop collecting, using, and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
8. After receiving your written request to withdraw consent, we may need a reasonable amount of time (depending on the complexity of the request and its impact on our relationship with you) to process your request and inform you of the consequences of complying with it, including any legal consequences that may affect your rights and liabilities with us. In general, we aim to process your request within ten (14) business days of receiving it.
9. While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we might not be able to continue providing our goods or services to you, and we will notify you before completing the processing of your request. If you decide to cancel your consent withdrawal, please inform us in writing in the manner described above.
10. Kindly note that withdrawing consent will not impact our right to keep collecting, using, and disclosing personal data when such actions without consent are allowed or mandated by applicable laws. To eliminate any doubt, withdrawing consent does not obligate us to erase any personal data we have already collected. Such retention is subject to prevailing laws, including laws governing retention of medical records.
11. If you wish to submit (a) an access request for a copy of the personal data we possess about you or information regarding how we use or disclose your personal data, or (b) a correction request to amend or update any of your personal data in our possession, you may send your request in writing or via email to our Data Protection Officer using the contact details provided below. Such requests should include the requester's details, a description of the personal data requested, and the date and time range when the personal data is believed to have been collected.
12. Be aware that a reasonable fee may be charged for an access request. If so, we will notify you of the fee before processing your request.
13. We will reply to your request as promptly as possible. Generally, our response will be within fourteen (14) business days. If we cannot respond to your request within thirty (30) days of receipt, we will notify you in writing within thirty (30) days regarding the time by which we will be able to address your request. If we cannot provide you with any personal data or make a correction as requested, we will typically inform you of the reasons for our inability to do so (except when we are not obligated to do so under the PDPA).
14. To protect your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented suitable administrative, physical, and technical measures, such as up-to-date antivirus protection, encryption, and disclosing personal data internally and to our authorized third-party service providers and agents only on a need-to-know basis.
15. We have implemented suitable technical and organizational security measures to protect the personal information we process. However, it is important to recognize that no electronic transmission over the Internet or information storage method is entirely foolproof. Despite our continuous efforts to strengthen the security of your information, we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties won't be able to compromise our security and unlawfully collect, access, steal, or modify your information. While we strive to protect your personal information, the transmission of personal information to and from our Services is at your own risk. We recommend that you only access the Services within a secure environment.
16. We generally rely on personal data provided by you (or your authorized representative). To ensure that your personal data is up-to-date, complete, and accurate, please inform us of any changes by contacting our Data Protection Officer in writing or via email at the contact details provided below.
17. We may allow you to delete some of the records stored on the Application by clicking "Settings" > "Delete." This action will only delete your records from the Application, but a backup copy may be retained under the following circumstances.
a. We may keep your personal data as long as necessary to fulfill the purpose for which it was gathered or as required or permitted by applicable laws.
b. We will stop retaining your personal data, or remove the means by which the data can be associated with you when it is reasonable to assume that retaining the data no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes.
18. We generally do not transfer your personal data to countries outside Singapore. However, if we do, we will take steps to ensure that your personal data continues to receive a standard of protection comparable to that provided under the PDPA.
19. If you have any questions or feedback about our personal data protection policies and procedures or wish to make any request, you can reach out to our Data Protection Officer using the contact information provided below:Data Protection OfficerContact No.: +65 88320233Email Address: [email protected]23. This Privacy Policy operates alongside any other notices, contractual clauses, and consent provisions that are applicable to the collection, use, and disclosure of your personal data by us.24. We reserve the right to update this Privacy Policy periodically without prior notice. You can determine if any revisions have occurred by checking the date when this Privacy Policy was last modified. By continuing to use our services, you acknowledge and accept any changes made to the Privacy Policy.
Effective date : 1 July 2023
Last updated : 1 July 2023